Shakespeare's Knowledge of Law
A Journey Through the History of the Arguments
(originally appeared in a slightly different form in The Oxfordian, October 2001)
II. The Early Advocates
Readers relying solely on Mr. Matus's "facts" would remain unaware of the nearly 200-year history of arguments over Shakespeare's legal knowledge in over thirty-five books and numerous articles. The nineteenth century saw a Golden Age of books supporting the proposition that Shakespeare possessed an extensive and unerring knowledge of the law.Table One: The Golden Age of Shakespeare's Law
Writer's skeptical of Shakespeare's knowledge of law appear in Bold.
1778 Edmond Malone "Essay on the Chronological Order of Shakespeare's Plays" 1780 Edmond Malone Life of William Shakespeare 1830 Anonymous "Shakspeare a Lawyer" The Legal Observer 1858 William Rushton Shakespeare a Lawyer 1859 Lord Campbell Shakespeare's Legal Acquirements 1859 William Rushton Shakespeare's Legal Maxims 1863 R. F. Fuller "Shakspere as a Lawyer" Upper Canada Law Journal 1865 Richard G. White "William Shakespeare Attorney at Law" Atlantic Monthly 1865 Richard G. White Memoirs of the Life of Shakespeare 1869 William Rushton Shakespeare's Testamentary Language 1870 William Rushton Shakespeare Illustrated by the Lex Scripta 1877 George Wilkes Shakespeare: an American Point of View 1883 Franklin Fiske Heard Shakespeare as a Lawyer 1883 Cushman K. Davis The Law in Shakespeare 1885 R.S. Guernsey Ecclesiastical Law in Hamlet 1897 Edward James Castle Shakespeare, Bacon, Jonson & Greene 1899 William Devecmon In Re Shakespeare's 'Legal Acquirements'
The first mention appears to have been made by the lawyer and Shakespeare editor Edmond Malone in his 1778 "Essay on the Chronological Order of Shakespeare's Plays," in a footnote to Hamlet. Two years later in his "Prolegomena" to The Life of William Shakespeare, he states that Shakespeare's "knowledge and application of legal terms, seems to me not merely such as might have been acquired by casual observation of his all-comprehending mind; it has the appearance of technical skill; and he is so fond of displaying it on all occasions, that there is, I think, some ground for supposing that he was early initiated in at least the forms of law" (II, 107-9).It seems that by 1830 the idea had taken root, since in November of that year, a law journal published an anonymous article entitled "Shakspeare [sic] a Lawyer," in which the writer makes reference to a number of authorities who support various notions of how Shakespeare came by his legal knowledge. Although the writer is critical of a number of theories, he himself finds the internal evidence persuasive:
The question of Shakspeare's connexion with the law must, after all, be decided by the internal evidence afforded by his writings; and in them we find the author recurring continually to the language of the law. He uses it with minute propriety, and like a man accustomed to it. The passages which might be produced to prove this are almost innumerable, and those which have been brought forward are neither few nor inconclusive. (1 Legal Observer 28)
But it was not until 1858-1859 that the idea began to flourish, after the publication of two books, William L. Rushton's Shakespeare a Lawyer and Lord Chief Justice John Campbell's Shakespeare's Legal Acquirements.
William Rushton
Rushton opens his work with his main propositions and addresses potential objections, and with an implied awareness of the Satan Maneuver:
The works of William Shakespeare contain a remarkable quantity of law terms, whose significances are naturally unknown to the generality of readers. Some of the admirers of our great dramatist may assert that the universality of his genius, the strength, vigour, and magnitude of his intellectual faculties and powers of investigation, enabled him to acquire a more profound knowledge of a greater variety of subjects than ever yet seems to have been possessed by the same individual, and that the legal knowledge he has displayed in the correct use of law terms is not more remarkable than his intimate acquaintance with human nature, and accurate observation of the habits and customs of mankind, or than the knowledge of seamanship, and the correct use of nautical terms he has displayed in the Tempest. To attempt to account for the frequent occurrence and correct use of law terms in Shakespeare's Works, by attributing to him knowledge of a great variety of subjects, is not satisfactory; for, Shakespeare's knowledge, it is generally admitted, was more intuitive than acquired, consisting more in an extensive and profound intimacy with human nature, with the animal and inanimate world,—which he has displayed with a truthfulness and inanimate power, and sublimity unapproached, if not unapproachable, rather than in a familiarity with the writings of authors and science in general,—and if that master mind could possibly have possessed double the unequalled genius which exalted him far above the generality of his fellow creatures, he would not have been able to use and apply law terms of a purely technical character in the manner appearing in his compositions, without considerable knowledge of that abstruse and mighty science, the law of England. Nor will it be satisfactory to state that the legal knowledge he has displayed in the correct use of law terms affords no more evidence of his having been a lawyer than the correct use of nautical terms and the knowledge of seamanship are peculiar to the Tempest,—those phrases are not of frequent occurrence, and that knowledge is not displayed in any other portion of his works. Moreover, if it can be proved, as there seems reason to believe, that the principles and practice of the law of real property were more generally understood by unprofessional people in Shakespeare's time than at the present day, that circumstance will not satisfactorily account for all Shakespeare's legal knowledge, because his works contain passages displaying not merely a knowledge of the principles and practice of the law of real property, but also of the common law, and of the criminal law, and a thorough intimacy with the exact letter of the Statute Law. (3-5)
What follows then are 45 pages of examples of legal terms found in the works, a discussion of their meanings, and an explanation of why they are significant. Afterwards, Rushton concludes: "… whether William Shakespeare was or was not a member of the legal profession, sufficient has probably been stated to prove that he had acquired a general knowledge of the laws of England" (50).
The alert reader, however, will immediately question both Rushton's propositions and the means he uses to support them. In his introduction, Rushton advances two primary propositions:
1. Quantity: Shakespeare's works contain a remarkable quantity of law terms.
2. Accuracy: Shakespeare's works display a correct use of law terms.
How does the quantity of legal terms make a case for more than a general knowledge of law? Rushton makes no quantitative comparisons with Shakespeare's fellow dramatists, so we are left to wonder if Shakespeare's use of legal terms is unusual. Exactly what establishes a "remarkable quantity"? Rushton's presentation is by no means exhaustive, as later writers reveal.
Rushton's second proposition seems to be on firmer ground. But if Rushton is not exhaustive in his study of Shakespeare's legal terms, how do we know that Shakespeare's use is unerring? Furthermore, Rushton attributes Shakespeare's accuracy to a personal understanding of their technical meaning. But since Shakespeare used sources such as Holinshed's Chronicles, how do we know that Shakespeare's accuracy and correct usage is not merely that of his sources? Again, Rushton fails to make the necessary comparisons to support his propositions.
Rushton also points our three possible objections that he attempts to refute:
1. Some may say his genius enabled him to acquire a more profound knowledge of law, but that cannot explain how he came "to use and apply law terms of a purely technical character."
Rushton correctly points out a possible weakness of relying on Shakespeare's "genius"—a Satan Maneuver—but he does nothing to convince us that Shakespeare's technical usage is not merely copied from his sources.
2. Some may say that "the legal knowledge he has displayed in the correct use of law terms affords no more evidence of his having been a lawyer than the correct use of nautical terms and the knowledge of seamanship are peculiar to the Tempest." But law terms appear far more frequently, and his knowledge of seamanship "is not displayed in any other portion of his works."
Indeed, one may be able to support a case that Shakespeare's use of law terms is unusually frequent, especially when compared to his use of other technical terminology, but Rushton still fails to compare Shakespeare's usage to his fellow dramatists, a critical blunder when arguing unusual frequency.
3. Some may say that "the principles and practice of the law of real property were more generally understood by unprofessional people in Shakespeare's time." But his works contain passages "displaying not merely a knowledge of the principles and practice of the law of real property, but also of the common law, and of the criminal law, and a thorough intimacy with the exact letter of the Statute Law."
Rushton is probably right to agree that real property had more general application and understanding among English gentlemen. And if a lesser case can be made that Shakespeare's personal knowledge and correct application of unusual technical terms in other legal branches is indeed unusual, then that may go a long way towards supporting a larger case that Shakespeare had some formal legal training. But Rushton does not adequately support the lesser case. He does not properly catalog terms apart from real property, nor does he bring in the necessary comparative data.
Spotting Rushton's weak arguments, reviewers were quick to jump on his small book. In a magazine edited by Charles Dickens, an anonymous reviewer, assuredly Dickens himself, writes an extended satirical essay that parodies men of a particular profession who have a penchant to read into Shakespeare's use of their technical terminology indications that Shakespeare was a master or serious student of that profession. Dickens humorously takes to task both Rushton and a clergyman who praises Shakespeare's vast biblical knowledge. Dickens begins:
MY OWN private belief is that W. Shakespeare was a hydropathic doctor, as I mean to prove from his works, and display to the world in a work of considerable magnitude that has been lately sent to press. In the mean time I interest myself about the opinions of others, and have just been buying two new publications on the subject of our mutual friend. One is by a clergyman, M.M. of Corpus Christi College, Cambridge, and displays from Shakespeare's works "the vastness of his Bible lore." The other is by an able lawyer, who believes that Shakespeare was a man of his own cloth, and that, if not actually in practice as an attorney, he was a man who could have passed a stiff examination in the common, criminal, and statue law. I, myself, being a hydropathist, declare that if he were living now, and paid me a sufficient sum for the good will, I should feel more than confidence in entrusting to him my establishment and making it Shakespeare late Slush, in Brash House, Drenchmore. I need hardly observe that the very first play in our friend's works, the Tempest, is the story of a great water-cure worked in an exceedingly bad case by one Prospero, and we all know how much in another play the very soul of the Duke of Clarence was benefited by the bare dreaming about a cold water bath. What a fine knowledge of the efficacy of a cold douche in the excitement of mania is expressed in Lear's request, made instinctively to the descending flood of rain—as dogs when sick instinctively apply themselves to certain grasses—"Pour on, I will endure!" Undoubtedly the unfortunate gentleman who showed this knowledge of what was proper to his case, would be represented on the stage by any really subtle actor as placing his head carefully under the drip from the rood of the hovel, in order that he might the better secure a sustained stream upon the occiput." (Household Words, Oct. 23, 1858, p. 454)
Dickens sustains his satire for another 2400 words. By the end, the reader is not left in doubt about his stand: Writers like Rushton are simply projecting their own interests onto Shakespeare's plays, and seeing in them the expertise that they themselves enjoy.
Since Dickens was not a lawyer, and he successfully supplied correct legal terms in legal contexts in his own works, including Great Expectations, David Copperfield, and Bleak House, we can easily appreciate his impulse to mock Rushton.1 Certainly, one is on very shaky ground arguing that an author must have had legal training, or shows an unusual knowledge of law and legal terms, merely because he or she is able to construct an accurate legal situation or a compelling courtroom scene with all legal terms properly used. Good writers, with study and the help of a few professional friends, can accomplish such feats without proving themselves legal experts or having legal training.2
Rushton received good reviews as well. A decade later, a reviewer in a law journal approves of Rushton's research. By that time Rushton had published three works on Shakespeare's law, including the one reviewed, Shakespeare's Testamentary Language:
Mr. Rushton has proved himself an able legal commentator of the works of Shakespeare. In addition to the above little book of comparison he has contributed largely to illustrate by old authors the language used by the immortal bard in his plays and poems. In this way he has satisfactorily explained many obscure expressions of doubtful meaning, and has offered explanations and suggestions of his own for the consideration of his readers. His "Shakespeare a Lawyer," and "Shakespeare's Legal Maxims," unmistakably show that if Shakespeare was not at one time connected with the law, as has been attempted to be shown by some of his biographers, yet by some unaccountable means he acquired extensive familiarity with technical legal phraseology. Shakespeare's plays abound with instances of much more than ordinary knowledge of law terms for a civilian, and in order to use these in the way he did, his acquaintance with the written and unwritten law of his period, combined with a tolerable display of legal jargon, must have been remarkable. There is no doubt sufficient internal evidence in his plays to warrant the belief that Shakespeare must at least have served in an attorney's office, and Lord Campbell and other commentators have laboured to support this inference. (27 Law Magazine and Review 162)
The reviewer refers to Chief Justice John Campbell's book Shakespeare's Legal Acquirements, which came out soon after Ruston's first book.
Lord Campbell
Shakespeare's Legal Acquirements covers much of the same territory as Shakespeare a Lawyer and follows Rushton's method of citing a series of legal terms used in the plays. In fact, some reviewers—and Rushton himself—thought that Campbell plagiarized Rushton's work. But some examples obviously lend themselves to similar interpretations, and Campbell does discuss examples not mentioned by Rushton.
Campbell groups his examples by plays. In his introductory letter of some 30 pages to John Payne Collier, Campbell outlines his theory that Shakespeare was likely an attorney's clerk before going on with over 80 pages of examples of Shakespeare's knowledge of law. Then Campbell spends several pages on Shakespeare's will, positing that Shakespeare himself drafted it. Campbell ends with a "Retrospect" of a dozen pages where he presents his uncommitted conclusions:
To conclude my summing up of the evidence under this head, I say, if Shakespeare is shown to have possessed a knowledge of law, which he might have acquired as clerk in an attorney's office in Stratford, and which he could have acquired in no other way, we are justified in believing the fact that he was a clerk in an attorney's office at Stratford, without any direct proof of the fact. Logicians and jurists allow us to infer a fact of which there is no direct proof, from facts expressly proved, if the fact to be inferred may have existed, if it be consistent with all other facts known to exist, and if facts known to exist can only be accounted for by inferring the fact to be inferred.
But, my dear Mr. Payne Collier, you must not from all this suppose that I have really become an absolute convert to your side of the question. (136-137)
Lord Campbell's book proved very influential, given his position as Chief Justice. Researchers spent years looking for legal documents that would necessarily have been signed by Shakspere of Stratford if he had indeed been a clerk in an attorney's office. No such documents have yet been found, which has for most scholars lay to rest the notion that he held such a position.3
But Campbell's book was not a work of scholarship. He admits in his introductory letter that he had a little leisure time during his vacation, that he is limiting the frame of his research to terms that may have been used by a professional lawyer, and that he is setting out to do less than a thorough job:
In The Two Gentlemen of Verona, Twelfth Night, Julius Caesar, Cymbeline, Timon of Athens, The Tempest, King Richard II., King Henry V., King Henry VI. Part I., King Henry VI. Part III., King Richard III., King Henry VIII., Pericles of Tyre, and Titus Andronicus—fourteen of the thirty?seven dramas generally attributed to Shakespeare—I find nothing that fairly bears upon this controversy. Of course I had only to look for expressions and allusions that must be supposed to come from one who has been a professional lawyer. Amidst the seducing beauties of sentiment and language through which I had to pick my way, I may have overlooked various specimens of the article of which I was in quest, which would have been accidentally valuable, although intrinsically worthless. (37-38)
Indeed, even in the works where he says he finds nothing that bears upon the controversy, he has overlooked significant passages, particularly in the Henry plays.
Lord Campbell's book suffers from many of the same faults as Rushton's. He does not attempt to prove a thesis much more complicated than "Shakespeare used lots of legal terms correctly, a use which therefore goes to show, given his biographical background, that he was likely an attorney's clerk in Stratford." He does show how Shakespeare uses terms from many courts and categories of law; i.e., the Court of Exchequer (49), the Courts of Common Law (52), the Court Leet (63), the Court of Common Pleas (66), the Court of Wards (68), Real Property Law (39), Admiralty Law (114), and with "some of the most abstruse proceedings in English jurisprudence" (44-45). And he does present examples that appear to grant Shakespeare a certain depth in the law. His first example is from The Merry Wives of Windsor:
Fal. Of what quality was your love, then?
Ford. Like a fair house built upon another man's ground; so that
I have lost my edifice by mistaking the place where I erected it.Now this shows in Shakespeare a knowledge of law, not generally possessed. The unlearned would suppose that if, by mistake, a man builds a fine house on the land of another, when he discovers his error he will be permitted to remove all the materials of the structure, and particularly the marble pillars and carved chimney-pieces with which he has adorned it; but Shakespeare knew better. He was aware that, being fixed to the freehold, the absolute property in them belonged to the owner of the soil… . (39-40)
Despite examples such as this, Lord Campbell generated harsh criticism, much of it deserved. In fact, the best articulated critique of his work, and that of Rushton, came from a non-practicing lawyer—Richard Grant White.
Richard Grant White
In July 1859, the Atlantic Monthly printed a 21-page article by Richard Grant White, "William Shakespeare Attorney at Law and Solicitor in Chancery," three-fourths of which he spends castigating Lord Campbell's mistakes, stylistic errors, and generally lousy scholarship. He gives Rushton more credit for the modesty of his writing and the organization of his examples, but overall White finds both works lacking in the kinds of arguments needed to argue that Shakespeare was a practicing attorney or had some kind of legal education. Furthermore, Grant White seems to be the first writer to point out an uncomfortable truth for advocates of Shakespeare's legal training: Shakespeare's use of legal terms in his histories often mirrors their use in his source material, mainly Holinshed's Chronicles. Any writer who embarks on making the case for Shakespeare's legal training must avoid the error of crediting Shakespeare's legal knowledge based on passages rewritten from Holinshed.
After perusing many pages of Grant White's article, the reader would think that he does not believe that support exists for Shakespeare's legal training, but in the latter part of the article, he delivers a surprise:
For we object not so much to the conclusion at which Lord Campbell arrives as to his mode of arriving at it. His method of investigation, which is no method at all, but the mere noting of passages in the order in which he found them in looking, through Shakespeare's works, is the rudest and least intelligent that could have been adopted…. (99)
Grant White then explores what he believes are "the very considerable grounds for the option that Shakespeare had more than a layman's acquaintance with the technical language of the law" (99). He makes several significant points:
First: Legal phrases frequently appear in the literature of that age and Shakespeare's use of legal terminology is remarkably pervasive and accurate even when compared to other dramatists. Grant White explicitly denies that the mere appearance of such terminology indicates early training (as Lord Campbell and Rushton would have it). Rather, many dramatists had such training, and for many, like George Wilkins, we do not have enough biographical material to determine whether they were trained in the law. Still, Shakespeare's pervasive and accurate use of legal terminology strengthens the argument that he had such training.
Second: Direct contemporary testimony exists that at the time of Shakspere of Stratford's arrival in England it was a common practice for lawyers to turn to writing plays. This testimony is from Nashe in the Preface to Greene's Menaphon: "It is a common practice nowadays, amongst a sort of shifting companions that run through every art and thrive by none, to leave the trade of Noverint whereto they were born, and busy themselves with the endeavours of art, that could scarcely Latinize their neck-verse if they should have need." (Nashe 474) The trade of "Noverint" is that of a lawyer. Grant White claims that the case is further strengthened because "among all the dramatic writers of that period, whose works have survived, not one uses the phraseology of the law with the frequency, the freedom, and the correctness of Shakespeare" (102).
Third: Although the argument is made that lay people commonly attended the London courts, and that Shakespeare could have easily picked up his terminology during such proceedings, White points out that many of the law terms used by him are not normally heard at such proceedings, especially terms having to due with real property and the technical language of conveyancers. Shakspere of Stratford's arrival in London coincides with early plays that already contain such language, "before he had had much opportunity to haunt the courts of law in London, even could he have made such legal acquirements in those schools" (103). Furthermore, with Shakspere's arrival in London, there is no general increase in the frequency of terms used in the plays, which may be expected if Shakspere were then to acquire a greater legal vocabulary.
Fourth: Grant White's strongest argument is that while Shakespeare correctly uses the technical language of many professions—physicians, actors, soldiers—primarily on special occasions, he exhibits a pervasive reliance on legal terms throughout his works, demonstrating an accuracy and propriety that transcends his contemporaries.
Must we believe, that the man, who, among all the lawyer-dramatists of his day, showed—not, be it noticed (as we are at present regarding his works) the profoundest knowledge of the great principles of law and equity, although he did that too—but the most complete mastery of the technical phrases, the jargon, of the law and of its most abstruse branch—that relating to real estate—and who used it very much the oftenest of them all, and with an air of as entire unconsciousness as if it were a part of the language of his daily life, making no mistakes that can be detected by a learned professional critic—must we believe that this man was distinguished among those play?writing lawyers, not only by his genius, but his lack of particular acquaintance with the law? (104)
Grant White concedes that there is no biographical proof that Shakspere of Stratford worked as an attorney's clerk or studied law formally. But he expresses no doubt about the writer Shakespeare: The poems and plays demonstrate some kind of formal legal training.
Other Early Writers
Following Rushton and Lord Campbell came several books exploring Shakespeare's use of legal terms, and one that included a dissenting view—George Wilkes' 1877 book Shakespeare from an American Point of View. He is also among the early writers responding against the claim that Francis Bacon wrote the Shakespeare plays. Believing firmly that Shakspere wrote Shakespeare, Wilkes reveals that he is not taken in by the Satan Maneuver:
Some critics, whose brows were more rainbowed than the rest, suggested that any extent of scholastic accomplished might fairly be attributed to the vivid, lambent quick-breeding conception of such a miracle of genius as was the poet of our race; but this exceptional theory made but little headway with more sober reasoners, mainly for the want of precedents that any man was ever known to have learned his letters, or attained to the art of making boots or watches by mere intuition. The fact is, that the true difficulty with this portion of the inquiry has been, that too much erudition and legal comprehension has been attributed to Shakespeare for what his law phrases indicate; or, in plainer words, they have been paraded at a great deal more than they are really worth." (72)
Thus does Wilkes lay down the central contention between the advocates: On one side, Rushton, Lord Campbell, and Grant White, who are impressed by Shakespeare's technical range, accuracy, and application. On the other, Dickens, Wilkes, and many others to come, who do not see an unusual technical range, who claim inaccuracies, and who do not see any extraordinary application of the law. Wilkes clearly lays down the means by which Shakspere of Stratford could have acquired his legal knowledge: a) by reading elementary works of law, b) by attending the courts of record held semi-monthly in Stratford, and courts-leet and view of frankpledge held semi-annually in Stratford, c) through his experience as a property owner, d) through lawsuits. Furthermore, Wilkes claims that where Shakespeare deals with the philosophy of law—in The Merchant of Venice, Comedy of Errors, Winter's Tale, Two Gentlemen of Verona, and Measure for Measure—he fails in ways that should be obvious to readers. Wilkes gives one example in support, criticizing the Duke in Two Gentlemen for appointing to high government posts the gang who kidnapped his daughter. However ineffective such an example serves as support, Wilkes' argument has merit, that Shakspere had the means to learn some of the technical terms of property law.
Later writers, such as Franklin Fiske Heard and Edward J. White, offer little more than catalogs of Shakespeare legal terms, with explications of their meanings.4 The best of the catalogers, Cushman K. Davis, in his 1883 book The Law in Shakespeare, expands the claims for Shakespeare's knowledge of law, based on the accumulated work of cataloging and explicating hundreds of terms in his book:
We seem to have here something more than a sciolist's temerity of indulgence in the terms of an unfamiliar art. No legal solecisms will be found. The abstrusest elements of the common law are impressed into a disciplined service with every evidence of the right and knowledge of commanding. Over and over again, where such knowledge is unexampled in writers unlearned in the law, Shakespeare appears in perfect possession of it. In the law of real property, its rules of tenure and descents, its entails, its fines and recoveries, and their vouchers and double vouchers; in the procedure of the courts, the methods of bringing suits and of arrests, the nature of actions, the rules of pleading, the law of escapes, and of contempt of court; in the principles of evidence, both technical and philosophical; in the distinction between the temporal and the spiritual tribunals; in the law of attainder and forfeiture; in the requisites of a valid marriage; in the presumption of legitimacy; in the learning of the law of prerogative; in the inalienable character of the crown—this mastership appears with surprising authority. (4-5)
Edward James Castle advances the cause of Bacon as Shakespeare in his 1897 Shakespeare, Bacon, Jonson, and Greene, which is poorly argued, especially in its approach to the question of Shakespeare's legal knowledge. The only other worthwhile argument after Grant White and before 1899 is in R. S. Guernsey's small book Ecclesiastical Law in Hamlet, which is best addressed in considering Shakespeare's legal mind.
The next phase of the argument, an increasing reaction against the rising tide of Baconian advocates, arrives with William C. Devecmon in 1899.
Footnotes
1. For an extended discussion of non-lawyers who accurately portray the law in fiction, see Kornstein's Kill All the Lawyers? p. 236. back2. Because trial scenes are easily created by non-lawyers, those scenes in The Merchant of Venice and Measure for Measure are not discussed in this essay. Andrews' The Law of Equity in The Merchant of Venice is often cited as a good argument for Shakespeare's mastery of the law of equity, but whatever the merits of that case, Andrews' argument is weak, in my opinion. I may address these two plays when this essay is expanded into a book. back
3. The one notable holdout is Eric Sams in his 1995 book The Real Shakespeare. back
4. Heard's Shakespeare as a Lawyer (1883), Davis's The Law in Shakespeare (1883), and White's Commentaries on the Law in Shakespeare (1911). back
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